https://www.taxtmi.com/caselaws?id=798554 Reassessment jurisdiction under Section 147 requires a correct factual foundation and genuine application of mind to material available to the Assessing Officer. Treating an assessee as a non-filer despite a return having been filed under Section 139(1) makes the satisfaction underlying the notice under Section 148A(b), the order under Section 148A(d), and the reassessment factually erroneous. Reliance solely on portal information without verifying the return record renders the assumption of jurisdiction unsustainable. The reassessment proceedings and consequential reassessment order were therefore invalid and set aside. en-us Wed, 25 Mar 2026 00:00:00 +0530 Wed, 09 Sep 2026 08:20:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798554 Reassessment jurisdiction under Section 147 requires a correct factual foundation and genuine application of mind to material available to the Assessing Officer. Treating an assessee as a non-filer despite a return having been filed under Section 139(1) makes the satisfaction underlying the notice under Section 148A(b), the order under Section 148A(d), and the reassessment factually erroneous. Reliance solely on portal information without verifying the return record renders the assumption of jurisdiction unsustainable. The reassessment proceedings and consequential reassessment order were therefore invalid and set aside. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798554